INTRODUCTION
Your privacy is very important to us. It is a priority of ours at Sydney Lodges that we are committed to protecting the personal information we collect from you. This privacy policy sets out our commitments to you in using your personal information, how we use it, and how we protect it.
1. Hiperoca Pty Ltd trading as Sydney Lodges and related bodies corporate (“Sydney Lodges”, “we”, “our”, or “us”) are committed to respecting the privacy of your personal information. This Privacy Policy explains how we deal with your personal information that we collect, use, hold, disclose or process.
2. We will update this Privacy Policy from time to time when we change how we deal with personal information. We will post any changes to this Privacy Policy on our Websites, so we encourage you to check this Privacy Policy from time to time.
3. In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy and consent provisions that apply to certain collection channels of personal information. Because those specific and additional provisions also relate to your privacy protection, we recommend that you review them wherever they appear.
Definition of personal information
4. Throughout this Privacy Policy, we use the term ‘personal information’ to refer to information relating to an identified or identifiable natural person, including information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not. For example, your full name, date of birth, address, mobile telephone number, email address and credit card details are examples of information which may constitute personal information. Personal information may also include information we may collect about your individual preferences.
Problems, Complaints or Queries
5. If you have any questions about our Privacy Policy, or any problems or complaints about how we have collected, used, stored, handled, disclosed and/or processed your personal information, please contact our privacy officer via email: info@sydneylodges.com.
ON WHAT BASIS DO WE PROCESS YOUR DATA?
Lawful basis of processing
6. We will only collect, monitor, use, disclose, or process any personal information about you with your consent (which we endeavour to obtain at the same time as collecting your personal information) or if it is otherwise lawful to do so. The only personal information collected by us is what has been provided to or collected by us in accordance with this Privacy Policy or has been provided to us lawfully by third parties. We will generally deal with your personal information for the primary purposes set out in this Privacy Policy.
7. We reserve the right to use or disclose any information, including personal information, as needed to satisfy any law, regulation or legal request, to protect the rights or property of us, any member of the Sydney Lodges group, or any member of the public, to protect the integrity of a Website, to fulfil your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety
WHEN AND HOW DO WE COLLECT PERSONAL INFORMATION?
Collection Channels
8. We collect and combine personal information in a number of ways through the following channels (each, a Collection Channel):
a. Your activities in relation to your stay at one of our properties including:
i) Booking a room
ii) Checking-in and paying
iii) Hotel stays and services provided during a stay
iv) Eating/drinking at the hotel bar or restaurant during a stay
v) Requests, complaints and/or disputes.
b. Participation in marketing programs or events:
i) Signing up for loyalty programs
ii) Participation in customer surveys
iii) Online games, competitions or promotions
iv) Subscription to newsletters, in order to receive offers and promotions via email.
v) Tour operators, travel agencies (online or not), GDS reservation systems and others
c. Our online properties (here and after, each a “Website”), including:
i) Our websites, including but not limited to www.sydneylodges.com;
ii) any related Sydney Lodges website, social media page, internal website, intranet and any Sydney Lodges mobile or tablet applications,
iii) online forms (online reservation, questionnaires, Sydney Lodges pages on social networks, social networks login devices such as Facebook login, conversations with chatbot).
d. any other means through which an individual provides personal information to us, including either physically or electronically.
ACTIVE INFORMATION COLLECTION
9. Personal information may be collected and combined via our Collection Channels if you:
a. sign-up and/or register to become a member of any Collection Channel, or provide your details to us via any Collection Channel;
b. subscribe to any newsletters, updates, alerts or news and media releases, or request launch or event information or information about our products or services or other information services, or participate in a promotion;
c. have previously provided us with personal information prior to this Privacy Policy coming into effect, either directly from you personally or via a third party;
d. complete and submit any forms or surveys provided to Sydney Lodges, either physically or electronically;
e. contact us directly in person or via any medium including mail, telephone, social media and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) including via the contact details listed on a Website;
f. interact with a Website for any purpose; or
g. we may also collect your information through other legitimate third party sources including list brokers, social media organisations, and other data providers or organisations that share data in circumstances where it is lawful and/or you have given permission for them to do so.
10. We may collect personal information from you in a passive manner including through the use of cookies and other tracking tools such as internet tags, tracking pixels, web beacons and unique device identifiers. For further information about the use of passive personal information collection, see paragraph 36 below.
WHAT KINDS OF PERSONAL INFORMATION DO WE COLLECT?
11. We may collect personal information including:
a. Contact details (for example, last name, first name, telephone number, email)
b. Personal information (for example, date of birth, nationality)
c. Information relating to your children (for example, first name, date of birth, age)
d. Your credit card number (for transaction and reservation purposes)
e. Information contained on a form of identification (such as ID card, passport or driver licence)
f. Your arrival and departure dates
g. Your preferences and interests (for example, smoking or non-smoking room, preferred floor, type of bedding, type of newspapers/magazines, sports, cultural interests, food and beverages preferences, reason for stay etc.)
h. Your questions/comments, during or following a stay in one of our Sydney Lodges branded establishments
i. Technical and location data you generate as a result of using our websites and application
Consequences of not providing personal information
12. No-one is obliged to provide personal information. However, failure to do so may result in us being unable to provide you with our goods, services, information, upcoming opportunity, promotion, event or product information, and other content, including where requested by you.
FOR WHAT PURPOSES DO WE COLLECT, HOLD, USE AND DISCLOSE YOUR PERSONAL INFORMATION?
13. Personal information that we collect will be used for the following primary purposes:
a. to manage your booking, our relationship with you including identifying you in our system and contacting you, invoicing you correctly, sending you our products and to address your expectations of us in respect of how we conduct our business;
b. to ensure that your personal information remains up-to-date and complete;
c. to facilitate payments from you;
d. to contact you, including sending you any technical, administrative or legal notices relevant to us or a Website;
e. to otherwise maintain our relationship with you including providing after sales services and responding to enquiries;
Special offers, marketing and advertising
f. to provide you with early access to new releases, exclusive events, special offers, newsletters, events, promotions and activations of Sydney Lodges;
g. to otherwise market to you (with direct marketing materials), via any medium including mail, telephone, commercial electronic messages (such as SMS, MMS, instant messaging, email, social media, mobile applications), or any other form of electronic, emerging, digital or conventional communications channel;
h. to provide you with relevant and targeted advertising, including when you browse third party websites;
Our Website
i. to maintain the functionality of a Website, including customising the Website based on your preferences; providing information to you relating to the content available on a Website; to improve the Website and system administration;
Miscellaneous
j. to share personal information with our group companies and their related bodies corporate and agents, and other trusted third parties in the manner described in this Privacy Policy;
k. any other purpose as may be deemed reasonably necessary by us in the circumstances.
Contact by Sydney Lodges
14. Sydney Lodges group companies (and their directors, servants and agents), our promotional partners or trusted third parties (and other selected service providers and other non Sydney Lodges companies or professionals) either in Australia or overseas, may contact you via telephone, SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, post or any other form of electronic, emerging, digital or conventional communications channel using the information provided in order to contact you in respect of the primary purposes for collection of personal information as stated above.
15. If you wish to remove your name from the database from receiving future advertising and marketing information, we may send you non-commercial “Administrative Emails”. Administrative Emails relate to your account with us and may include administrative and transaction confirmations, requests and inquiries or information about a particular account. If you do not wish to receive such communications from us you may remove your name from the database by contacting our Privacy Officer. Please allow 30 days for this request to be processed.
HOW DO WE SHARE YOUR PERSONAL INFORMATION?
16. Solely for the purposes described above, personal information may be shared with the entities below including their directors, servants and agents and related bodies corporate of our:
a. technical service providers, such as mail carriers, hosting providers, IT companies and communications agencies; and
b. other trusted service providers, promotional partners and third parties.
17. These recipients may be engaged by us to perform a variety of functions, such as legal and accounting services, data storage, support services, conducting market research, processing credit card payments, assisting with promotions and providing technical services for our websites. These companies may have access to personal information if needed to perform such functions. Your credit card details are only used to facilitate your purchases.
HOW DO WE HOLD, AND HOW LONG DO WE HOLD YOUR PERSONAL INFORMATION?
Security
18. We take appropriate security measures to keep personal information secure and to prevent unauthorised access, disclosure, modification, misuse, interference or loss of personal information. Sydney Lodges, its employees and its subcontractors are obliged to respect the confidentiality of any personal information held by us.
19. We also take reasonable steps to keep personal information accurate, up to date, complete and relevant. We take reasonable steps to ensure only those necessary have access to your personal information. Personal information is stored on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers. In some cases these facilities may be overseas. We retain your information only for as long as necessary for the purposes listed in this Privacy Policy. We will inform you about serious data breaches in accordance with the Privacy Act.
20. We hold on to your personal information for a reasonable time in the circumstances you have provided us your personal information, whilst at all times complying with applicable laws. The length of time and what is reasonable varies depending on whether the personal information is in relation to:
a. Managing your booking and stay at a hotel; or
b. Necessary for our legitimate interest in running our business and providing you with requested products and services.
YOUR PRIVACY RIGHTS
21. You have a number of rights under the Australian Privacy Law These include:
a. (access) to request access to your personal information from us, in a commonly used electronic format. On a case by case basis, we may determine that it is not legally required to give an individual access to personal information, in which case we will provide you with a written notice of its refusal to provide access;
b. (correction) to request that we correct your personal information;
c. (withdrawing consent) to withdraw your consent for us to use your personal information. Please note that you can also opt-out of online marketing communications at any time by using the unsubscribe feature in each electronic commercial message; and
d. (complaint) to complain about a breach of the Australian Privacy Principles.
22. To exercise these rights, please contact us at the contact details listed at the beginning of this Privacy Policy. Please allow for a reasonable amount of time for us to process your request, which will generally be up to 30 days.
Children
23. The information collected in relation to persons under 16 years of age is limited to their name, nationality and date of birth, which can only be supplied to us by an adult. We would be grateful if you could ensure that your children do not send us any personal data without your consent (particularly via the internet). If such data is sent, you can contact us to arrange for this information to be deleted.
Passive Information Collection
24. As with many commercial websites (and mobile and tablet applications), we may also collect information which tells us about visitors to our websites. For example, we may collect information about the date, time and duration of visits and which pages of a Website are most commonly accessed. This information is generally not linked to the identity of visitors, except where a Website is accessed via links in an email we have sent or where we are able to uniquely identify the device or user accessing a website. By accessing a Website via links in an email we have sent and/or by accessing a Website generally including when you are logged into an account, you consent to the collection of such information where it is personal information.
25. Our Websites may use and combine such passively collected anonymous information or personal information and/or information from various third party sources, including as described above, and may combine this anonymous information or personal information with other personal information collected from you to provide better service to website visitors and users, customise a website based on your preferences, compile and analyse statistics and trends, provide you with relevant advertising when you visit a Website or a third party Website, and otherwise administer and improve a Website for your use.
Sydney Lodges and other websites
26. Our Websites may, from time to time, contain links to the websites of other organisations which may be of interest to you. Their inclusion cannot be taken to imply any endorsement or validation by us of the content of the third party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements. We are not responsible, nor does it accept any liability, for the conduct of companies linked to our Websites.
User submissions
27. We may provide areas on a Website where you can upload user-generated content, post or provide information about yourself, communicate with other users, provide reviews for content, products and/or services or interact with or vote on particular content. This information may be shared with others and may be publicly posted on our Websites, including without limitation, other social media platforms and other public forums in which you choose to participate. This information may become publicly available and may be read, collected and used by others outside of our Websites. We are not responsible for the conduct of others who may read, collect and use this information.
For more information about our privacy policy, please contact a Sydney Lodges participating property or the Sydney Lodges head office.
